This is a topic I have written about several times before and EPA has made their position fairly clear in their RMP Q&A’s. SAFTENG members can CLICK HERE to read the summary of the EPA Q&A’s regarding railcars that are NOT attached to a mode of transport (i.e. locomotive). These railcars that sit out on a spur that is SEPARATE from the “process” are actually their own “process” (e.g. they are not connected to the process and they are not located close enough that they could impact a process – but they exceed the TQ for a covered process). So when we have this type of arrangement on site, we would have to report the railcars as a “process” just like our regular type process. As we will see in this inspection, EPA took issue that these groups of railcars that were on site were not reported as a “process” in the facility’s RMP, the facility had not done a PHA on the railcar groupings (e.g. covered process) and no audit had been done. If you are wondering why there were not other elements cited, these situations are unique in that the facility most often does NOT own the rail cars so it is not like we have PSI on them. But if they are on site and NOT attached to their mode of transport we have to claim them as a process. If we have enough cars linked together or even in close proximity to one another then we have to examine this arrangement as a “process” and determine if we exceed the TQ for the materials stored in them. Here is the case: